Appendix 1
MILTON KEYNES COUNCIL: BASIC GRADING AND PAY STRUCTURE PROPOSALS: REPORT OF
EQUALITY IMPACT ASSESSMENT
1. Introduction
1.1 I am asked to undertake an Equality Impact Assessment (EqIA) in relation to the Milton Keynes
Council proposals in relation to basic grading and pay; and as part of this to further check the gender
impact of the proposed boundary between the NJC JES and Hay system of evaluation.
1.2 A gender Equality Impact Assessment is an analysis of a proposed change to an organisational
policy to determine whether it has a disparate impact on one gender and, if so, whether it can be
justified without reference to the relevant diversity feature. It applies both to external policies, those
having an impact on the customers of clients or the organisation; and to internal policies, that is
those affecting the organisation’s employees.
1.3 An EqIA in relation to pay involves:





comparing pay data from the old and proposed new pay structures in order to determine
the impact of the proposals in relation to gender,
reviewing proposed changes to grading and pay policies, and changes to other terms and
conditions, if any, to identify any gender related differences arising from the proposals,
deciding whether any disparate impact is objectively justified,
and, if not, amending the proposals;
agreeing an action plan to eliminate any outstanding gender pay differences.
1.4 An Equality Impact Assessment is essentially a ‘before’ and ‘after’ Equal Pay Review for the
employees covered by the grading and pay structure proposals. The principles, techniques and steps
are therefore similar to those for an Equal Pay Review. This EqIA follows the steps and techniques
recommended in the Equality and Human Rights Commission (EHRC) Equal Pay Review Model
[available on the EHRC website].
1.5 This report relates only to the proposed basic grading and pay structures. Other terms and
conditions are currently under negotiation and need to be covered by an equality impact assessment
once firm proposals are on the table. I understand that this is planned. It is reasonable to undertake
an equality impact assessment exercise in stages as the UK equal pay legislative provisions (under
the Equality Act 2010 for Great Britain) relate to individual contractual terms.
1.6 This report is based on pay data and other information supplied by MK Council. The pay data
omits vacant posts, as there is obviously no gender impact in relation to unoccupied posts. The data
also omits employees in a small number of recently transferred posts, which have not yet been
evaluated.
2. Statistical Analysis
2.1 The impact of the proposals is most appropriately identified by comparing average pay by gender
for those undertaking equal work, measured in this context by the proposed new ‘grades’. In terms
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Appendix 1
of equal pay auditing using the EHRC Equal Pay Review Model, this is effectively a ‘before’ and ‘after’
‘work rated as equivalent’ check, as each proposed new grade can be treated as ‘work rated as
equivalent’, in the terms of UK equal pay legislation, as set out in the Equality Act 2010.
TABLE 2.1: ANALYSIS OF CURRENT BASIC AND PROPOSED AVERAGE FULL TIME EQUIVALENT SALARIES BY
PROPOSED GRADE AND GENDER
Proposed
Grade
A
B
C
D
E
F
G
H
I
J
W
[J/W
X
Y
Z
All above
Nos.
F
361
466
128
1148
457
435
162
186
69
50
1
51
10
13
14
3500
Current Basic Pay (£)
M
12
53
42
123
131
109
40
69
31
30
1
31
6
12
10
669
F
12,481
13,766
16,346
17,320
20,735
24,658
28,989
33,572
37,252
43,928
45,175
43,952
48,576
53,528
60,908
20,253
M
12,598
13,451
16,652
17,750
20,682
25,759
30,865
36,850
39,054
44,646
41,616
44,548
49,836
52,041
59,924
25,643
F as % of
M
99.1
102.3
98.2
97.6
100.3
95.7
93.9
91.1
95.4
98.4
108.6
98.7
97.5
102.9
101.6
79.0
Proposed Basic Pay
(£)
F
M
12,587
12,631
14,230
14,117
16,342
16,425
18,137
18,219
20,718
20,583
24,569
25,059
28,946
29,525
33,545
34,822
37,787
38,528
43,150
43,432
45,000
41,616
43,186
43,374
48,000
48,500
53,462
53,517
61,643
61,300
20,577
25,302
F as % of
M
99.7
100.8
99.5
99.5
100.7
98.0
98.0
96.3
98.1
99.4
108.1
99.6]
99.0
99.9
100.6
81.3
2.2 Equality and Human Rights Commission (EHRC) advice for equal pay reviews is that gender grade
pay gaps of 5% or more (highlighted in bold in table 2.1) should be treated as significant, requiring
further investigation to identify the cause; gaps of between 3 and 5% (highlighted in italics) could
also be indicative of gender pay discrimination, if they form part of a pattern. These indicators of
significance are equally appropriate to an equality impact assessment.
2.3 As can be seen from Table 2.1, in relation to current pay, there are a number of significant
gender grade pay gaps in favour of men from proposed grade F through to I. All the gender grade
gaps, in favour of both men and women, are reduced, or in one case remain essentially the same,
under the grading and pay structure proposals. The significant gaps are all reduced to less than 3%,
as one would expect in a structure whose aim is to move towards equal pay for work of equal value.
2.4 There is a significant grade gap in favour of women in proposed grade W, in relation to both
current and proposed pay, but numbers in this grade are very small and the gap is reduced to less
than 3% when grades J and W, which share the same pay scale, are combined.
2.5 The overall gender pay gap is influenced by the distribution of men and women across the
relevant grades, as well as by pay structure issues. The current overall gender pay gap for the Milton
Keynes Council employees covered by this analysis is 21.0%. Under the pay structure proposals, the
overall gender pay gap reduces to 18.7%. This remaining gender pay gap is attributable to the
distribution of males and females across the proposed grades. A gap of this size is of some concern
from an equal opportunities perspective, but that is outside the remit of this report.
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Appendix 1
Red, Green (and White) Circle Analysis
2.6 The gender pay gap analysis in relation to basic pay is usefully supplemented by examining the
pattern of movement between grades as a result of the job evaluation exercise. These movements
are summarised in Table 2.2 below, where ‘green’ circles are those whose proposed basic pay is
higher than their current basic pay, ‘white’ circles are those whose proposed basic pay is the same as
their current basic pay and ‘red’ circles are those whose proposed basic pay is lower than their
current basic pay.
TABLE 2.2: ANALYSIS OF ‘GREEN’, ‘WHITE’ AND ‘RED’ CIRCLES IN RELATION TO PROPOSED BASIC PAY BY GRADE AND
GENDER
Proposed
Grade
A
Nos
F
361
12
255
9
89
1
17
2
B
466
53
285
37
90
7
91
9
C
128
42
79
26
12
5
37
11
D
1148
123
652
60
360
41
136
22
E
457
131
145
56
244
50
68
25
F
435
109
253
45
78
19
104
45
G
162
40
61
11
50
12
51
17
H
186
69
56
4
89
22
41
43
I
69
31
27
8
32
13
10
10
J/W
51
31
28
19
4
2
19
10
X
10
6
7
4
0
0
3
2
Y
13
12
5
7
0
0
8
5
Z
14
10
6
5
0
0
8
5
Total
3500
669
1859
291
1048
172
593
206
84.0
16.0
86.5
13.5
85.9
14.1
74.2
25.8
%
All
% of all
Green Circles
F
M
M
4169
100
2150
51.6
White Circles
F
M
1220
29.3
Red Circles
F
M
799
19.2
2.7 Table 2.2 shows, as one would expect in an exercise moving towards equal pay for work of equal
value, that there are disproportionately higher proportions of male than female ‘red’ circles in
relation to basic pay and of female than male ‘green’ circles. The overall proportion of ‘green’ circles
is relatively high, at 51.6%. However, the proportion of ‘red’ circles is also quite high at approaching
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Appendix 1
20% (19.2%) and may merit further investigation, especially the number of female red circles in
grade F where they almost 25% of females in the grade. Conversely, the numbers and proportions of
‘white’ circles are relatively low by comparison with similar exercises elsewhere, demonstrating that
there is a high level of both upward and downward movement.
2.8 This is further investigated in relation to ‘green’ circles in table 2.3 below. This shows pretty
much what one would expect, with disproportionately high numbers and percentages of female
green circles compared to male green circles in most grades especially towards the bottom of the
proposed grading structures. Average green circle amounts are also generally higher for females
than males and this is true of the overall average.
TABLE 2.3: ANALYSIS OF ‘GREEN’ CIRCLES IN RELATION TO BASIC SALARIES BY GRADE AND GENDER
Proposed
Nos in Grade
Grade
A
F
361
M
12
B
466
C
Green Circles
9
264
F/M Circles as % of
Green Circles
F
M
T
96.6
3.4
100
285
37
322
88.5
11.5
100
1125
1106
170
79
26
105
75.2
24.8
100
1521
786
123
1271
652
60
712
91.6
8.4
100
1929
1820
457
131
588
145
56
201
72.1
27.9
100
1719
1535
F
435
109
544
253
45
298
84.9
15.1
100
1358
1512
G
162
40
202
61
11
72
84.7
15.3
100
2237
1548
H
186
69
255
56
4
60
93.3
6.7
100
2494
804
I
69
31
100
27
8
35
77.1
22.9
100
2430
1772
J/W
51
31
82
28
19
47
59.6
40.4
100
780
506
X
10
6
16
7
4
11
63.6
36.4
100
1409
590
Y
13
12
25
5
7
12
41.7
58.3
100
1709
3369
Z
14
10
24
6
5
11
54.5
45.5
100
2257
3158
Total
3500
4169
1859
291
2150
86.5
13.5
100
1476
1416
373
F
255
53
519
128
42
D
1148
E
669
T
M
T
Average
Amount (£)
F
M
222
196
2.9 The analysis in relation to the ‘red’ circles is shown in Table 2.4 below. While the gender patterns of red
circles are much as one would expect in an exercise moving towards equal pay for work of equal value, the
average red circle amounts are high. The overall average red circle amounts are almost twice as high as the
green circle amounts for women and more than twice as high for me. Inspection of the raw data shows that
this is partly on account of there being some high individual red circle amounts. For example, there are 4
employees (1 male and 3 female) with red circle amounts of more than £10,000. There are also relatively few
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Appendix 1
small red circles. Together these features result in high average amounts. Somewhat disconcertingly, the
average female red circle amounts in grades A to D, F, H and X are higher than for males in those grades.
2.10 These figures must result from acute historical pay anomalies or from the way jobs have been evaluated
or some combination of both. It may be worth analysing the reasons for the highest male and female red
circles and re-checking the job evaluations before publishing the results. I am aware that some of this review
has already been undertaken and more is ongoing.
TABLE 2.4: ANALYSIS OF ‘RED’ CIRCLES IN RELATION TO BASIC SALARIES BY GRADE AND GENDER
Proposed
Nos in Grade
Grade
A
F
361
M
12
B
466
C
373
17
2
19
F/M Red Circles as %
of All
F
M
T
89.5
10.5
100
53
519
91
9
100
91.0
9.0
100
1152
623
128
42
170
37
11
48
77.1
22.9
100
3264
2726
D
1148
123
1271
136
22
158
86.1
13.9
100
2356
2339
E
457
131
588
68
25
93
73.1
26.9
100
3779
3955
F
435
109
544
104
45
149
69.8
30.2
100
3672
3207
G
162
40
202
51
17
68
75.0
25.0
100
2813
4153
H
186
69
255
41
43
84
48.8
51.2
100
3525
3329
I
69
31
100
10
10
20
50.0
50.0
100
2867
3049
J/W
51
31
82
19
10
29
65.5
34.5
100
3205
4602
X
10
6
16
3
2
5
60.0
40.0
100
5207
5188
Y
13
12
25
8
5
13
61.5
38.5
100
1176
1176
Z
14
10
24
8
5
13
61.5
38.5
100
407
407
Total
3500
4169
593
206
799
74.2
25.8
100
2713
3108
669
Red Circles
T
F
M
T
Average
Amount (£)
F
M
1068
685
3. Proposed Changes to Basic Pay Policies
Even where pay gaps narrow and there are no significant gender grade pay differences, the EHRC
recommends that all relevant pay policies be reviewed from an equality perspective.
Job Evaluation
3.1 Milton Keynes Council is proposing to underpin its new grading and pay structures for by job
evaluation. Job evaluation is an acknowledged technique for moving towards equal pay for work of
equal value, but it is important that both the design of the scheme and its implementation are fair
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Appendix 1
and non-discriminatory. This can be checked using checklists provided as part of the Equality and
Human Rights Commission (EHRC) Equal Pay Review Model (EPRM), Guidance Note 4, Job Evaluation
Schemes Free of Sex Bias.
3.2 Milton Keynes Council has used the Local Government Services NJC Job Evaluation Scheme for
jobs in proposed grades A to J. This scheme was designed to underpin single status pay structures in
the sector, and was developed specifically to cover all relevant jobs and to comply with equal value
principles and practices. For grades W to Z, the Council has used the Hay system of evaluation.
Grading Structure
3.3 Grade ranges are as follows:
TABLE 3.1: JE GRADE RANGES AND NUMBERS OF EMPLOYEES BY PROPOSED GRADE AND GENDER
Grade
JE Min
JE Max
No. of
Points
No. of
Employees
F
M
361
12
% of grade
% of gender
A
-
257
-
T
373
F
96.8
M
3.2
F
10.3
M
1.8
B
258
305
48
466
53
519
89.8
10.2
13.3
7.9
C
306
343
38
128
42
170
75.3
24.7
3.7
6.3
D
344
383
40
1148
123
1271
90.3
9.7
32.8
18.4
E
384
422
39
457
131
588
77.7
22.3
13.1
19.6
F
423
467
45
435
109
544
80.0
20.0
12.4
16.3
G
468
502
35
162
40
202
80.2
19.8
4.6
6.0
H
503
554
52
186
69
255
72.9
27.1
5.3
10.3
I
555
596
42
69
31
69.0
31.0
2.0
4.6
J/W
597
761
NA
51
31
82
62.2
37.8
1.5
4.6
X
762
889
138
10
6
16
62.5
37.5
0.3
0.9
Y
890
989
100
13
12
25
52.0
48.0
0.4
1.8
Z
990
-
-
14
10
24
58.3
41.7
0.4
1.5
3500
669
4169
84.0
16.0
100
100
100
3.4 Milton Keynes Council is proposing a 13-grade structure for those jobs covered by the ‘single
status’ grading and pay structure review, that is, up to and including head of service roles. This is a
slightly larger number than many local authorities in England and Wales have adopted for a similar
range of jobs, where new grading structures typically have between 9 and 12 grades, but it does not
seem unworkable, as very large numbers of grades can be. There are no equality implications in the
number of grades, as such.
3.5 In terms of the JE points - the split between NJC and Hay is above 637 points when roles which
have NJC scores in excess of this have their HAY score applied. The HAY outcome is inflated by 290
Page 6 of 12
Appendix 1
points in order to establish the points to grades for levels W, X, Y, Z. There is an overlap with those
scoring between NJC points 597-637 falling into J, whilst those with less than 761 Hay(+290 ) points
are classified as grade W. The salary points for both J and W are the same.
3.6 There is nothing in any of the analyses for this Equality Assessment report which raises any
additional equality issues, other than those identified in previous analyses, in relation to the
boundary between the two job evaluation schemes being at NJC JES 637 points, with jobs with
scores above this being evaluated on the Hay system. Hay evaluated grade W contains only one male
and female, so there are no apparent inequalities here.
3.7 Although the NJC JES job evaluation grade ranges are broadly similar, there are variations from
39 to 52 points, so there is no obvious arithmetic or other logical justification to underpin these
ranges (see also para. 3.9 below).
3.8 The second half of Table 3.1 shows the numbers of employees in each of the proposed new
grades by gender. Women form more than four fifths (84.0%) of the Single Status workforce and
dominate in all grades in the proposed structure, but by much smaller proportions in proposed
grades I to Z. Looked at another way, around 60% of the female workforce are in grades A to D,
whereas the comparable figure for males is just over 30%. These are primarily equal opportunities
issues of who does what job and thus outside the scope of this report, but in relation to the pay
structure, it gives rise to a need to ensure that female-dominated jobs have been correctly evaluated
and graded relative to male-dominated jobs.
Grade Boundary Analysis
3.9 Positioning of grade boundaries (rather than their number or range) can give rise to equality
issues, if, for example, significant female dominated jobs fall immediately below a grade boundary
where there is a male-dominated job above, so that it may appear that the grade boundary has been
positioned to prevent the women from achieving equal pay with the man or men. The employer
would then need to provide objective justification for the positioning of the grade boundary. This
situation can usually be tested for by analysing the gender dominance of jobs immediately above
and below each grade boundary. This is sometimes called a boundary proximity analysis.
3.10 It can be seen from Table 3.2 that, although there are a number of grade boundaries with
female-dominated jobs immediately below and male-dominated jobs above, the jobs in question are
generally accompanied by jobs of opposite gender dominance, so it would be difficult to argue that
there was discriminatory impact to the positioning of the grade boundaries. The exceptions are
grade boundaries B/C, G/H and I/J, although the jobs in question are not large group jobs. However,
it is wise to double check the evaluations of jobs immediately above and below the grade
boundaries; and also to record the reasons behind the positioning of the grade boundaries, in case
of future query.
Page 7 of 12
Appendix 1
TABLE 3.2: GENDER ANALYSIS OF JOBS IMMEDIATELY BELOW AND ABOVE GRADE BOUNDARIES
Grades
Boundary
Female Dominated Jobs Immediately Below
A/B
257
JE0820
JE
Points
240
B/C
C/D
D/E
305
343
383
JE0660
Male dominated job
JE0574, 0575, 0576
305
381
E/F
422
JE0418
421
F/G
467
466
G/H
H/I
I/J
W/X
X/Y
502
554
596
761
889
JE0289, 0290, 0325, 0328, 0347, 0360, 0764, 0975
+ individual male jobs
JE0236, 0260
JE0143, 0144
JE0106
JE0035
JE0511
Y/Z
989
Male and female jobs
-
502
553
595
756
884
Male Jobs Immediately Above
Female dominated jobs
Also xx points gap
JE0493
Female dominated jobs
JE0571, 0572
+ female dominated job
JE0470
+ female dominated job
Female dominated jobs
JE0256
Individual male and female jobs
JEX006
Mixed gender job
JE0059
+ Female dominated jobs
Male and female jobs
JE
Points
306
384
423
469
503
556
600
769
901
-
Pay Structure
3.11 Milton Keynes Council is proposing the salary structure shown in Table 3.3. As can be seen from
the table, the proposed pay scales have either 3 (minimum plus 2 incremental points) or 4 (minimum
plus 3 incremental points). Recommended good practice in relation to both gender and age
discrimination is that scales should not have more than 5 incremental steps, as it is considered that
up to this number can be justified on the general basis that experience improves performance. The
MK pay scales comply with this recommended good practice. There is no legal requirement from an
equality perspective that all pay scales have the same number of increments, because employees in
different grades are not undertaking equal work, so have no basis for challenge under UK equal pay
legislation. It can also be seen from Table 3.3 that all pay scales are discrete, that is, there are no
overlaps. Avoidance of pay scale overlaps avoids potential equal pay risks.
TABLE 3.3: JE GRADE AND SALARY RANGES
Grade
JE Min
JE Max
No. of
Points
A
B
C
D
E
F
G
H
I
J/W
X
Y
Z
258
306
344
384
423
468
503
555
597
762
890
990
257
305
343
383
422
467
502
554
596
761
889
989
-
48
38
40
39
45
35
52
42
NA
138
100
-
Scps
Salary
Min £
Salary
Max £
6, 7, 8
9, 11, 13
14, 16, 18
19, 20, 21
22, 23, 24, 25
26, 27, 29, 31
32, 33, 35, 37
38, 39, 40, 42
43, 44, 45, 47
48, 49, 50, 52
53, 54, 55
56, 57, 59
61, 63, 64
12,489
13,589
15,725
17,802
19,621
22,221
27,052
31,754
36,313
40,741
46,500
51,500
58,000
13,189
15,444
17,162
19,126
21,519
26,276
30,851
35,430
39,855
45,000
49,500
55,500
64,000
Headroom Analysis
3.12 The proposed pay scales are shorter than the current Milton Keynes pay scales, which also
overlap. While reducing scale length and eliminating overlap is beneficial from an equality
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Appendix 1
perspective, it will also impact on the pay expectations of employees. The proposed new pay scales
are congruent with the existing ones at only one point, the maximum of proposed grade E which is
the same as the maximum of current grade 5. This means that pay expectations change for the great
majority of employees, as can be seen from Table 3.4.
TABLE 3.4: ANALYSIS OF HEADROOM GAINERS AND LOSERS IN RELATION TO PROPOSED BASIC PAY BY GRADE AND
GENDER
Proposed
Nos
Grade
A
F
M
Headroom Gainers
Headroom Same
F
F
M
M
Headroom
Losers
F
M
Off Scale
F
M
361
12
342
10
0
0
19
2
0
0
B
466
53
246
27
0
0
212
23
8
3
C
128
42
73
26
0
0
48
13
7
3
D
1148
123
982
93
0
0
161
28
5
2
E
457
131
73
45
299
58
80
25
5
3
F
435
109
295
51
0
0
137
58
3
0
G
162
40
97
19
0
0
65
20
0
1
H
186
69
123
17
2
1
60
49
1
2
I
69
31
53
16
0
0
16
15
0
0
J/W
51
31
30
20
0
0
21
11
0
0
X
10
6
7
4
0
0
3
2
0
0
Y
13
12
2
4
0
0
11
8
0
0
Z
14
10
4
4
0
0
10
6
0
0
Total
3500
669
2327
336
301
59
843
260
29
14
84.0
16.0
87.4
12.6
83.6
16.4
76.4
23.6
67.4
32.6
%
All
% of all
4173
100
2663
63.8
360
8.6
1103
26.5
43
1.1
3.13 The figures in Table 3.4 are arrived at by subtracting the current scale maximum from the
proposed scale maximum. The figures do not relate directly to those in Table 2.2 for a number of
reasons:


those currently on off scale salaries are excluded from the analysis because they do not have
scale maxima;
in most cases, those who are white circles basic pay because their salary remains as it
currently is under the proposals are divided between headroom gainers and headroom
losers;
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Appendix 1

most who are green circles in relation to basic pay are also headroom gainers, as one would
expect, but some are headroom losers (see below).
3.15 In general terms, looking at headroom shows a higher proportion of gainers than when looking
at basic pay (63.8% compared with 51.6%). This is true overall and for most grades; it is especially
true for females. However, it also results in a higher proportion of losers (26.5% compared with just
under 20%). The most significant exception is in grade B, where a large number of those who are
green circles in relation to basic pay, because of the deletion of some current scale points, become
losers. This is because the maximum of proposed scale B is lower than the maximum of nearest
current equivalent grade 3. This has a particularly adverse impact on female employees, because of
the high female dominance in this grade.
4. Conclusions
4.1 In summary, in relation to the proposed basic grading and pay structures:

Analysis of current and proposed pay shows that, as should be expected in an exercise
designed to comply with equal opportunities legislation, all the gender grade basic pay gaps
narrow under the Milton Keynes Council grading and pay structure proposals for single
status employees, and all to less than significant levels.

The overall gender pay gap in relation to basic pay also narrows from 21.0% to 18.7%,
marking a significant step towards equal pay among the employees covered by the grading
and pay proposals.

As one would also expect in an exercise moving towards equal pay for work of equal value,
analysis of those gaining and losing in relation to their basic pay shows that there are
higher proportions of female than male basic pay gainers and of male than female basic pay
losers. The overall patterns are broadly reflected in the individual grades. Average full time
equivalent red circle amounts are unusually large. Inspection of the raw data shows some
large red circles and relatively few small red circles. The figures indicate either significant
historical pay anomalies or some queries over evaluation outcomes or both. The reasons for
the largest red circles merit investigation.
(MKC response: The reasons for the largest red circles are under investigation and where
necessary, further moderation will be undertaken. If the outcome stands, a record will be
made of the rationale.)

Milton Keynes Council is proposing to underpin its new grading and pay structures for ‘single
status’ employees by job evaluation. It has used the Local Government Services NJC JES for
jobs scoring up to 673 points and the Hay system of evaluation for those above this. The
proposed pay structure has an overlapping pay scale for grade J on the NJC JES and grade W
on Hay, but there are only 2 employees in proposed grade W, one male and one female. The
analysis, therefore, neither adds nor subtracts from the separate equality analyses
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Appendix 1
undertaken in relation to the positioning of the grade boundary between the two job
evaluation schemes.

Milton Keynes Council is proposing a 13 grade structure to cover jobs up to and including
heads of service roles. There are no equality implications in the number of grades.

Analysis of jobs proximate to grade boundaries shows that, although there are a number of
grade boundaries with female-dominated jobs immediately below and male-dominated jobs
above, the jobs in question are invariably accompanied by jobs of opposite gender
dominance, so it would be difficult to argue that there was discriminatory impact to the
positioning of the grade boundaries. The exceptions are grade boundaries B/C, G/H and I/J,
although the jobs in question are not large group jobs. However, it IS wise to double check
the evaluations of jobs immediately above and below the grade boundaries.
(MKC Response: The grade boundaries have been checked. They are placed at the
position that makes most sense taking account of current pay levels to minimise
turbulence. No boundary is placed in a position that discriminates on the basis of
gender.)

The proposed pay structure has scales with minimum point plus either 2 or 3 incremental
points. This is consistent with recommended good practice in relation to both gender and
age discrimination which is that scales should not have more than 5 incremental steps. It is
considered that up to this number can be justified on the general basis that experience
improves performance.

The proposed pay scales are discrete, in that the maximum point of each lower grade is one
scale point lower than the minimum of the next higher grade. There is thus no point at
which an employee on the higher grade can be paid less than an employee on the lower
grade (as can occur with overlapping pay scales) and there is therefore no possible source of
challenge under equal pay legislation in relation to this aspect of the proposals.

The headroom analysis demonstrates changes to pay expectations for most employees. In
general terms, looking at headroom shows a higher proportion of gainers than when looking
at basic pay (63.8% compared with 51.6%). This is true overall and for most grades; it is
especially true for females. However, it also results in a higher proportion of losers (26.5%
compared with just under 20%). The most significant exception is in grade B, where a large
number of those who are green circles in relation to basic pay, because of the deletion of
some current scale points, become losers, because the maximum of proposed scale B is
lower than the maximum of nearest current equivalent grade 3. This has a particularly
adverse impact on female employees, because of the high female dominance in this grade.
(MKC Response: The majority of roles within grade B are for less than 50% of the working
week and within the school environment (67 are full-time roles, 510 are part-time roles
of which 387 are less than 50% of a full-time role). The high proportion of females is
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Appendix 1
perhaps due to the limited hours available within these roles. The Council recognises the
issue of gender segregation within roles and would want to remove this where feasible,
but this is outside the scope of this project.)
Sue Hastings
2nd July 2013
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